Sandra,
It was issued December 30. The contract is boilerplate from the state and I doubt they know. I think the FAR should be updated, but I also think their language implies the UG. I was just wondering if others concurred with me.
Thanks.
Carolyn
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Sandra Nordahl
Sent: Monday, February 02, 2015 12:40 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] FAR 31.3 question
Carolyn,
Was the contract issued before 12/26? If so, then OMB A-21 would still apply. I just checked the FAR site and the regulations have not been updated to reflect the new uniformed guidance. You may want to contact the contracting officer.
Sandra
Sandra M. Nordahl, CRA
Director, SR Contracting and Compliance
and Facility Security Officer
San Diego State University Research Foundation
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San Diego, CA 92182-1934
email: xxxxxx@foundation.sdsu.edu
voice: 619.594.4172
fax: 619.582.9164
www.foundation.sdsu.edu
and
Immediate Past President
Society of Research Administrators International
www.srainternational.org
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On Mon, Feb 2, 2015 at 7:54 AM, Carolyn Elliott-Farino <xxxxxx@kennesaw.edu> wrote:
I have a cost reimbursement contract that references the FAR 31.3, which I had thought would have been revised to mention the Uniform Guidance instead of A-21. It does say “in accordance with the revision of OMB Circular A-21 in effect on the date of the contract” and that would include the UG, right?
Subpart 31.3—Contracts with Educational Institutions
This subpart provides the principles for determining the cost of research and development, training, and other work performed by educational institutions under contracts with the Government.
Office of Management and Budget (OMB) Circular No. A-21, Cost Principles for Educational Institutions, revised, provides principles for determining the costs applicable to research and development, training, and other work performed by educational institutions under contracts with the Government.
(a) Contracts that refer to this Subpart 31.3 for determining allowable costs under contracts with educational institutions shall be deemed to refer to, and shall have the allowability of costs determined by the contracting officer in accordance with, the revision of OMB Circular A-21 in effect on the date of the contract.
(b) Agencies are not expected to place additional restrictions on individual items of cost.
Thanks.
Carolyn
Carolyn Elliott-Farino
Executive Director, Office of Research
Kennesaw State University &
Kennesaw State University Research and Service Foundation
3413 Kennesaw Hall, MD #0111
585 Cobb Avenue, Kennesaw, GA 30144
470-578-6381
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